mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011462.json

{
  "document_metadata": {
    "page_number": "12",
    "document_number": "734",
    "date": "07/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 12 of 16\n\nNovember 19, 2021\nPage Twelve\ndistrict have ordered plaintiffs to produce their EVCP releases to Maxwell (in one case with the amount redacted), so she is already aware of the content of the EVCP's general release.49\n\nForcing the EVCP to turn over information it promised all claimants it would keep confidential—an indispensable condition that victims relied upon—would “disembowel the very core” of this program and others like it.50 Compliance would be unreasonable and oppressive and, accordingly, this Court should quash the subpoena.\n\nB. The documents sought are inadmissible under Federal Rule of Evidence 408.\n\nThe subpoena should also be quashed because the records sought are inadmissible under Federal Rule of Evidence 408. Rule 17(c), in general, authorizes subpoenas returnable before trial, as well as subpoenas returnable at trial “to obtain impeachment material.” United States v. Donziger, No. 19-CR-561 (LAP), 2021 WL 1865376, at *4 (S.D.N.Y. May 10, 2021). The test set forth in Nixon “governs both varieties” of subpoenas. Donziger, 2021 WL 1865376, at *4. Under Nixon, the subpoena must “clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity.” Nixon, 418 U.S. at 700. Here, Maxwell's subpoena fails, at a minimum, to clear the admissibility hurdle, because Rule 408 makes the documents sought largely, if not entirely, inadmissible.\n\nUnder Rule 408(a), evidence of accepting a valuable consideration to compromise a claim, as well as statements or conduct made in connection with negotiations about the claim, are “not admissible—on behalf of any party—either to prove or disprove the validity or amount of a disputed claim or to impeach by a prior inconsistent statement or a contradiction.” Fed. R. Evid. 408(a). Inadmissibility under Rule 408 provides a basis to quash a Rule 17(c) subpoena. See49 See Order, dated Feb. 16, 2021 (ECF No. 120), at 2 in Farmer v. Indyke, 19 Civ. 10475 (S.D.N.Y.); Order, dated Mar. 19, 2021 (ECF No. 102) ¶ 2, in Doe v. Indyke, 20 Civ. 484 (S.D.N.Y.).\n50 Ex. A ¶ 14 (Feldman Decl.).\n\nDOJ-OGR-00011462",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 12 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 19, 2021\nPage Twelve\ndistrict have ordered plaintiffs to produce their EVCP releases to Maxwell (in one case with the amount redacted), so she is already aware of the content of the EVCP's general release.49\n\nForcing the EVCP to turn over information it promised all claimants it would keep confidential—an indispensable condition that victims relied upon—would “disembowel the very core” of this program and others like it.50 Compliance would be unreasonable and oppressive and, accordingly, this Court should quash the subpoena.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. The documents sought are inadmissible under Federal Rule of Evidence 408.\n\nThe subpoena should also be quashed because the records sought are inadmissible under Federal Rule of Evidence 408. Rule 17(c), in general, authorizes subpoenas returnable before trial, as well as subpoenas returnable at trial “to obtain impeachment material.” United States v. Donziger, No. 19-CR-561 (LAP), 2021 WL 1865376, at *4 (S.D.N.Y. May 10, 2021). The test set forth in Nixon “governs both varieties” of subpoenas. Donziger, 2021 WL 1865376, at *4. Under Nixon, the subpoena must “clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity.” Nixon, 418 U.S. at 700. Here, Maxwell's subpoena fails, at a minimum, to clear the admissibility hurdle, because Rule 408 makes the documents sought largely, if not entirely, inadmissible.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Under Rule 408(a), evidence of accepting a valuable consideration to compromise a claim, as well as statements or conduct made in connection with negotiations about the claim, are “not admissible—on behalf of any party—either to prove or disprove the validity or amount of a disputed claim or to impeach by a prior inconsistent statement or a contradiction.” Fed. R. Evid. 408(a). Inadmissibility under Rule 408 provides a basis to quash a Rule 17(c) subpoena. See49 See Order, dated Feb. 16, 2021 (ECF No. 120), at 2 in Farmer v. Indyke, 19 Civ. 10475 (S.D.N.Y.); Order, dated Mar. 19, 2021 (ECF No. 102) ¶ 2, in Doe v. Indyke, 20 Civ. 484 (S.D.N.Y.).\n50 Ex. A ¶ 14 (Feldman Decl.).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011462",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Feldman"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "November 19, 2021",
      "07/15/22",
      "Feb. 16, 2021",
      "Mar. 19, 2021",
      "May 10, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 734",
      "19 Civ. 10475",
      "20 Civ. 484",
      "19-CR-561 (LAP)",
      "ECF No. 120",
      "ECF No. 102",
      "DOJ-OGR-00011462"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Maxwell. The text discusses the inadmissibility of certain documents under Federal Rule of Evidence 408 and the quashing of a subpoena. The document includes citations to relevant case law and court orders."
}